Privacy Information
DATE REVISED: 7/2025
POLICY: It is the policy of Benjamin Rose to comply with all applicable privacy and data protection laws. This Privacy Policy summarizes what personal information Benjamin Rose may collect, how Benjamin Rose may use this information, and other important topics relating to privacy and data protection.
PURPOSE: To promote compliance with privacy and data protection laws.
SCOPE:
Benjamin Rose (the “Organization,” also “we” or “us”) respects your right to privacy. This Privacy Policy summarizes what personal information we may collect, how we may use this information, and other important topics relating to your privacy and data protection.
It is the Organization’s policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our clients, business partners, and others who share their personal information with us.
This Policy applies to all Internet sites and mobile applications operated by or on behalf of the Organization and its affiliates and subsidiaries, including www.benrose.org and https://institute.benrose.org/ (each an “Organization Internet Site or App”). It also applies to personal information we may otherwise collect: (i) through our products, services and webinars; (ii) when you interact with us by means other than an Organization Internet Site or App, for example, in person or by telephone; and (iii) from our clients, distributors, suppliers, vendors, and other business partners (collectively “Business Partners”).
The Organization’s Collection, Use and Disclosure of Personal Information
Consistent with applicable law, whenever the Organization collects personal information, we endeavor to:
- provide timely and appropriate notice to you about our data practices;
- collect your personal information only for specified and legitimate purposes. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected;
- process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented;
- take commercially reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date;
- not use your personal information for direct marketing purposes without giving you an opportunity to “opt-out”; and
- take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within the Organization.
Sources of Personal Information the Organization Collects
The Organization collects personal information from the following sources:
- Information You Provide: The Organization collects personal information you provide us, which may include: (i) contact information, such as your name, company name, job title, address, e-mail address, and phone number; (ii) additional information about how you use our products or services; (iii) comments, questions, requests and orders you may make; (iv) financial information needed to process payments if you make purchases or donations, such as credit card or account information or tax identification number; and (v) information about your preferences, such as your preferred methods of communication and the types of services in which you are interested.
- Information Automatically Gathered from Your Device: Device and browser information. The Organization may collect technical information about your device, such as device type, browser type, IP address, operating system, and device identifier. The Organization collects this information automatically from your device and web browser through cookies and similar technologies.
Information about how you interact with us. The Organization may collect technical data about your usage of Organization Internet Sites or Apps and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, Organization promotional emails opened, and dates and times of interactions. The Organization collects this information using cookies and similar technologies.
Location information. The Organization may collect location information, including precise real-time location information from your device and imprecise location information derived from, for example, your IP address or postal code. Organization Apps will NOT access precise-real time location information from your device unless you grant permission to do so. - Cookies, Pixels and Similar Technologies: A “cookie” is a file of information placed on your device when you visit a website. Cookies and similar technologies can enhance your user experience by saving your preferences, personalizing your online experience, and sometimes providing you with advertising which is tailored to your interests.
“Pixels” (also called “web beacons” or “web tags”) are tiny graphics or scripts that communicate information from your device to a server. Pixels can be embedded in online or mobile content, videos, advertisements, or emails. They allow a server to read certain types of information from your device, such as when you viewed the pixel (and thus the content in which it is embedded) and the IP address of the device on which you viewed it.
Organization Internet Sites or Apps may use “session cookies.” A session cookie does not identify you personally and expires after you close your browser.
Organization Internet Sites or Apps may also use “persistent cookies.” These cookies do not expire when you close your browser. Persistent cookies stay on your computer until you delete them or they expire. By assigning your computer a unique identifier, we are able to create a database of your previous choices and preferences which can be provided by us automatically, saving you time and effort on future visits.
You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled. You may wish to visit www.aboutcookies.org which contains comprehensive information on how to modify the cookie settings on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies. For information on how to do this on the browser of your mobile phone or tablet you will need to refer to your device manual. Please note that you will not be able to opt out of receiving certain cookies that are strictly necessary for the delivery of a service requested by you.
Pixels may involve the transmission of information on our behalf to another party. We and our service providers use pixels for various purposes, including to track the actions of users, compile statistics about usage of Organization Internet Sites or Apps, provide content and ads that are more relevant to you, and measure response rates and effects of marketing campaigns. - Analytics: Organization Internet Sites or Apps may use Google Analytics 4 (GA4), a web analytics service provided by Google LLC (“Google”). GA4 collects data using cookies and other tracking technologies to analyze website traffic and user interactions. The information collected about your use of an Organization Internet Site or App, including your anonymized IP address, is processed by Google and stored on servers in the United States or other locations.
Google uses this data to evaluate website usage, generate reports for website operators, and provide other services related to website activity and internet usage. In GA4, IP addresses are not logged or stored, and data collection relies on event-based tracking rather than session-based tracking. Google may also share this information with third parties where required by law or where such third parties process data on Google’s behalf.
You can manage cookie preferences through your browser settings. Additionally, you can opt out of Google Analytics tracking across all websites by using the Google Analytics Opt-out Browser Add-on.
By using this Organization Internet Site or App and not opting out of Google Analytics tracking, you consent to the processing of your data by Google as described above. Information from Business Partners and other Third Parties.
The Organization collects personal information through our Business Partners. This information may include contact information, such as name, company name, job title, address, e-mail address, and phone number.
The Organization may also obtain personal information from other third-party sources, including publicly and commercially available sources. We may combine the information we receive from our Business Partners and other third-party sources with information that we collect from you or your device, as described above. - Personal Health Information: If you voluntarily participate in research studies conducted by the Organization or receive certain health related services, the Organization may collect personal health information (“PHI”). The federal Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) outlines strict guidelines to ensure the privacy and confidentiality of any PHI the Organization may collect from you. To learn more about the Organization’s compliance with HIPPA, please review the Organization’s Notice of Privacy Practices.
You have choices about the personal information you provide the Organization. You may choose not to provide information that we request, but if you do so, we may not be able to provide you a relevant service or a particular feature for an Organization Internet Site or App.
How the Organization Uses Your Personal Information
The Organization may use your personal information to:
- Develop and manage our relationships with you and our Business Partners. This may include: (i) delivering services or carrying out transactions that you or our Business Partners have requested; (ii) providing information about the Organization’s products, services, and transactions, and advertisements, that may be of interest to you; (iii) providing you and our Business Partners a more consistent experience in interacting with the Organization, including by learning more about you and how you use and interact with Organization Internet Sites or Apps, products, and services; and (iv) planning, managing, and performing under our contractual relationships with our Business Partners.
- Communicate with you or your company. This may include: (i) informing you of the Organization’s products, services, and promotional activities that may be of interest to you or your company; (ii) providing information about relevant Organization products, services, and transactions, including, for example, pricing information, technical data, invoice, shipping, or production information, warranty or recall information, or information about product or service improvements; (iii) responding to questions or inquiries that you make, including customer service requests; and (iv) inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys.
- Provide and improve our Internet Sites or Apps, products, and services. This may include: (i) customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use; (ii) maintaining the security of and otherwise protecting them; and (iii) developing new Organization Internet Sites or Apps, products and services.
- Address legal issues. This may include: (i) complying with our obligations to retain certain business records for minimum retention periods; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal process; (iv) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of Organization Internet Sites or Apps, products or services; and (v) protecting the Organization’s rights or property, or yours or others’ health, safety, welfare, rights, or property.
The Organization may also use your personal information for other uses consistent with the context in which the information was collected or with your consent.
The Organization may anonymize or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually.
When the Organization May Share Your Personal Information
The Organization may disclose your personal information in the following ways:
- The Organization may share your personal information with other Organization entities. When we do so, these other Organization entities will use your information in a manner consistent with this Policy and all applicable privacy and data protection laws.
- The Organization may also share your personal information with Business Partners we hire to perform support services for us. These third parties are required to use the personal information we share with them only to perform services on our behalf and to treat your personal information in compliance with all applicable privacy and data protection laws.
- In some cases, the Organization may share your personal information with Business Partners who partner with us to collaborate on research projects or to provide products and services to our clients, such as distributors. If so, we will require such Business Partners to use that information in a manner consistent with this Policy and all applicable privacy and data protection laws.
- The Organization may share your personal information with third parties when we have a good faith belief that disclosure is necessary: (i) to comply with a law, regulation, court order, or other legal process; (ii) to detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violation of law, or other misuse of Organization Internet Sites or Apps, products or services; (iii) to protect the Organization’s rights or property or your or others’ health, safety, welfare, rights, or property; or (iv) to serve purposes similar to those in (i)-(iii). If such an event occurs, we will take appropriate steps to protect your personal information.
- The Organization may share your personal information with third parties in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of the Organization or an Organization business unit, or under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.
- The Organization may share your information with your permission or at your request.
The Organization may share anonymized or aggregated information internally and with third parties for any purpose. Such information will not identify you individually.
Security of Your Personal Information
Your personal information in the Organization’s custody will generally be stored in the Organization’s databases or databases maintained by our service providers on servers located in the United States. The Organization takes commercially reasonable measures, including by contract or otherwise, to provide protection for personal information that is disclosed to a third party, including transfers within the Organization.
The Organization maintains reasonable safeguards to protect the confidentiality, security and integrity of your personal information. Although we use security measures to help protect your personal information against unauthorized disclosure, misuse, or alteration, as is the case with all computer networks linked to the Internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond our reasonable control.
Links to Third Party Internet Sites and Plugins
Organization Internet Sites or Apps may contain links to websites or mobile apps that are not operated by the Organization and plugins from social media platforms and other third parties. An example of a social media plugin is the Facebook “Like” button. We provide these links and plugins as a courtesy and do not imply any endorsement of the activities or content of the related websites, apps, or social media platforms, nor any association with their operators. To learn about the information collected by these third-party websites, apps, and plugins, please visit their privacy policies. We encourage you to review the privacy policies for the websites, apps, and social media platforms you visit before using them or providing personal information.
Retention of Your Personal Information
How long we keep your personal information will vary and will depend on the purpose and use of information collected. There are legal requirements that we keep some types of data for specific periods. Otherwise, we will retain it for no longer than is necessary for the purposes for which the data was collected.
Children
Organization Internet Sites or Apps are not intended for children under 13 years of age. The Organization will not knowingly solicit or collect personal information from or about children under 13, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law.
Additional Information for EU Residents
- The Organization’s lawful basis for processing your personal data: The lawful basis for the Organization’s processing of your personal data will depend on the purposes of the processing. For most personal data processing activities covered by this Privacy Policy, the lawful basis is that the processing is necessary for the Organization’s legitimate business interests. Where we process personal data in relation to a contract, or a potential contract, with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. When we are required to share personal data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law, for example, before we collect precise location data from your mobile device.
Processing on the basis of legitimate business interests. When we process personal information on the basis that the processing is necessary for our legitimate business interests, such interests include: (i) providing, improving, and promoting Organization Internet Sites or Apps, products, and services; (ii) communicating with current and potential customers, other Business Partners, and their individual points of contact; (iii) managing our relationships with our customers and other Business Partners, and their individual points of contact; (iv) other business development purposes; (v) sharing information within the Organization, as well as with service providers and other third parties; and (vi) maintaining the safety and security of our products, services and employees, including fraud protection.
Processing on the basis of performance of a contract. Examples of situations in which we process personal information as necessary for performance of a contract include e-commerce transactions in which you purchase a product or service from the Organization, on your own behalf, through an Organization Internet Site or App.
Processing on the basis of consent. Examples of processing activities for which the Organization uses consent as its legal basis include: (i) collecting and processing precise location information from your mobile device; (ii) sending promotional emails when consent is required under applicable law; and (iii) processing personal data on Organization Internet Sites or Apps through cookies and similar technologies when consent is required by applicable law.
Processing because the Organization is under a legal obligation to do so. Examples of situations in which the Organization processes personal data to comply with its legal obligations include: (i) payment of taxes and other government levies; (ii) providing your personal data to law enforcement agencies and other governmental bodies when required by applicable laws; (iii) retaining business records required to be retained by applicable laws; and (iv) complying with court orders or other legal process. - Additional information about the retention of your personal data: To determine the period for which your personal data will be retained in accordance with this Policy, the Organization considers criteria such as: (i) any applicable legal requirements to retain data for a certain period of time; (ii) any retention obligations related to actual or potential litigation or government investigations; (iii) any retention requirements in relevant agreements with our Business Partners; (iv) the date of your last interaction with the Organization; (v) the length of time between your interactions with the Organization; (vi) the sensitivity of the data; and (vii) the purposes for which the data was collected.
- Your individual rights: In accordance with the applicable laws in the European Union, you have the following rights with respect to your personal data, which apply differently in different circumstances: right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability, and right to object to processing. Most of these rights are not absolute. Below we describe these rights in more detail and provide information on how you can exercise them. If you make a request to exercise your rights, we will respond within one month, but have the right to extend this period by two additional months, where necessary. If we extend the response period, we will let you know within one month from your request.
You can exercise your rights by contacting:
Benjamin Rose
Phone number: (216) 373-1640
Email: myinfo@benrose.org
Right of Access. You have the right to ask the Organization to confirm whether we process your personal data. If we do, you have the right to request access to your personal data that we process and the following information: (i) the purposes of the processing; (ii) the categories of personal data we process; (iii) the recipients or categories of recipients of your personal data; (iv) the envisaged retention period of the data where possible, or the criteria we use to determine the retention period; (v) if we have not collected the data from you, any information we have available about the source of the data; and (vi) whether we use your personal data to make any automated decisions that have legal or other similar significant effects on you.
Right to rectification. You have the right to have the Organization correct your personal data if they are inaccurate. Taking into account the purposes of the processing, you may also have the right to have incomplete personal data about you completed, including by providing a supplementary statement to the Organization.
Right to object to processing for the Organization’s legitimate business interests. You have the right to object to the Organization processing your personal data when that data is processed on the basis of the Organization’s legitimate business interests. The Organization will honor your objection and stop processing the relevant personal data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, and freedoms; or (ii) we need to continue processing your personal data to establish, exercise, or defend a legal claim.
Right to object to processing for direct marketing. If the Organization processes your personal data for direct marketing purposes, you have the right to object to this processing. If you exercise this right, the Organization will stop processing your personal data for direct marketing purposes.
Right to restrict processing. You have the right to request that the Organization restrict the processing of your personal data in the following circumstances: (i) for the period of time the Organization needs to verify the accuracy of your personal data when you contest its accuracy; (ii) when the processing of your personal data is unlawful and you oppose the erasure of the data, and instead request that the Organization restrict the use of the data; (iii) when the Organization no longer needs your personal data for the purposes of processing, but you need the data to establish, exercise, or defend a legal claim; or (iv) for the period of time the Organization needs to verify if it has compelling legitimate grounds for processing that override your interests, rights, and freedoms when you object to the processing of your personal data for the Organization’s legitimate business interests.
If following your request, the Organization restricts the processing of your personal data, we will store your data, and otherwise process it only: (i) with your consent; (ii) to establish, exercise, or defend a legal claim; (iii) to protect the rights of another natural or legal person; or (iv) for reasons of important public interest of the European Union or a Member State. The Organization will also inform you before lifting the restriction of processing.
Right to erasure. The right to erasure is also called the “right to be forgotten.” You may ask the Organization to delete your personal data. This right is not absolute. The Organization is required to delete your personal data upon your request only in the following circumstances: (i) your personal data is no longer necessary for the purposes for which we collected or processed them; (ii) if the Organization processes your personal data on the basis of consent, you withdraw your consent, and no other legal ground exists for us to continue processing your personal data; (iii) if the Organization processes your personal data for its legitimate business interests, you object to the processing, and there are no overriding legitimate grounds for us to continue processing your personal data; (iv) if the Organization has processed your personal data unlawfully; or (v) the personal data must be erased to comply with a legal obligation under European Union or Member State law to which the Organization is subject.
The Organization is not required to erase your personal data to the extent that the Organization needs to process them to: (i) exercise its right of freedom of expression and information; (ii) comply with a legal obligation under European Union or Member State law to which the Organization is subject; or (iii) to establish, exercise, or defend a legal claim.
Right to data portability. You have the right to receive personal data you provided to the Organization when: (i) the processing of the data is based on your consent or is necessary for the performance of a contract between you and the Organization; (ii) the Organization’s processing of your personal data is carried out by automated means; and (iii) complying with your request will not adversely affect the rights and freedoms of others.
If you have the right to receive such personal data and request that we provide it, the Organization will provide it to you in a structured, commonly used, and machine-readable format.
Right to lodge a complaint with a supervisory authority. The Organization will use its best efforts to address and settle any requests or complaints brought to its attention. In addition, you have the right to approach the competent data protection authority with requests or complaints. This can be the supervisory authority in the country or federal state where you live.
Questions about this Policy
If you have any questions about this Policy or our use of your personal information, please contact:
IT Administrator
11890 Fairhill Road
Cleveland, OH 44120
Phone number: (216) 373-1640
Email: myinfo@benrose.org
Changes to this Policy:
Changes to this Policy will be posted on this site, along with information on any material changes. The Organization reserves the right to update or modify this Policy at any time and without prior notice. Any modifications will apply only to the personal information we collect after the posting.